Make Flight Training in the Electric-Powered Pipistrel ALPHA Electro Legal!

I am seeking an exemption from Section 14 CFR 1.1 Light Sport Aircraft which will allow the electric-powered Pipistrel ALPHA Electro Light Sport Aircraft to be used for private and commercial purposes with all the benefits and restrictions of light sport aircraft operating in the United States.

I am requesting a review, removal or exemption of the word "reciprocating" from the legislation which I believe unintentionally restricts electric propulsion. I request this definition be changed to:

"A single engine, if powered."

OR

"A single non-turbine engine, if powered.

It is my belief that the word reciprocating was originally added to avoid the complications of turbine and jet aircraft being introduced into the light sport aircraft category which were originally introduced as low-performance, simple, easy to operate aircraft.

If this word change is not possible or feasible in the near term, we are requesting that the Pipistrel ALPHA Electro be exempt from this definition so that it can be granted an Light Sport Aircraft airworthiness certification.

The relief I am seeking, and the reason I am seeking the relief

At the time that this registration category was introduced electric aircraft technology was in its infancy. With regular improvements in battery technology electric aircraft now being produced by certified aircraft manufacturers. These aircraft are being built and flown in compliance with FAA accepted ASTM standards but these aircraft can’t be LSA registered and operated in the USA because of the word reciprocating in the Section (6) definition.

I request that the word "reciprocating" be removed from the Light Sport Aircraft definition, which is the only thing that prevents the fully ASTM-complaint Pipistrel ALPHA Electro from being certified as a Light Sport Aircraft. Short of that, we are requesting an exemption from this definition so that the Pipistrel ALPHA Electro can be granted a Light Sport airworthiness certification immediately.

The Pipistrel ALPHA Electro can be registered outside of the USA as LSA aircraft and they are currently flying without restrictions.

The reasons why granting my request would be in the public interest and how it benefits the public as a whole

Electric aircraft by their definition produce no pollution during operation. If recharging is carried out by solar panels and/or wind turbine (renewable energy) then the electric aircraft fleet can operate without any adverse effects to the environment.

Electric aircraft are ideally suited to training operations where they can fly within one hour of their designated airport, return and recharge. As battery technology improves the range of electric aircraft will be extended.

Noise testing has been carried out and the Pipistrel ALPHA Electro aircraft operates at less than 50% of the noise of a comparable gasoline powered training aircraft on takeoff and landing and in many documented cases an Pipistrel ALPHA Electro aircraft flying overhead at 500 feet can’t be heard above normal ambient noise.

For airports that have community noise issues then electric powered aircraft will go a long way to satisfying residential demands and requirements for less noise during operation, this will be a major benefit to the public and will influence the public’s perception that every aircraft is loud and obnoxious.

As the world’s leading, electric aircraft manufacturer Pipistrel has entered into several partnerships and projects including the Sustainable Aviation Project in central California.

This is a public-private collaboration to reduce the cost of flight training through the use of all-electric general aviation/LSA airplanes, which effectively reduces flight training costs by 70%. The Sustainable Aviation Project partners include the City of Reedley, City of Mendota, Reedley College, several local flight schools, the Fresno Business Council, and the CALSTART San Joaquin Valley Clean Transportation Center.

A similar program has now been extended to the Los Angeles region with the recent delivery of 2 Pipistrel ALPHA Electro aircraft to Tomorrow's Aeronautical Museum and Flight School in Compton, where the mission is helping students from low income families avoid a life of crime and drugs and instead pursue careers in aviation and aerospace.

There are an additional four Pipistrel Alpha Electros on order to be delivered to the United States and substantial interest has been received from flight training operations based in Minneapolis, Florida and Indiana.

The airport of Santa Monica, California is making arrangements for government supervised noise testing at their airport as soon as our recently delivered Electric aircraft located in Compton are issued with a certificate of airworthiness.

Why granting this exemption would not adversely affect safety

Safety is an critical aspect in aviation. Electric propulsion actually enhances safety over conventionally-powered aircraft because there is only one moving part. There are no risks of carburetor icing, and no oil or gasoline to deal with. The batteries each have their own management system which protects against any risk of overheating. Beyond that, the Pipistrel ALPHA Electro is a glider with a 17:1 glide ratio, so it is estimated that there are only 6 seconds during the takeoff sequence where it may not be possible to make a safe return to the airport in the unlikely event of a catastrophic loss of power on takeoff.

Pipistrel has been an early pioneer in this area. Pipistrel entered the electric aircraft market in 2007 with the world’s first 2 seat electric aircraft, the Taurus Electro. In 2011, Pipistrel introduced the world’s first 4 seat electric aircraft which still flies to this day as a technology demonstrator. In 2012, the 2nd generation of Pipistrel electric aircraft propulsion systems were released. NASA is one of Pipistrel's largest customers of electric propulsion systems.

Pipistrel began development on the Pipistrel ALPHA Electro in 2014, and began worldwide deliveries in May 2017. Pipistrel's factory test/demonstrator has over 2000 flight hours without incident. The airplane meets the latest revisions ASTM F2245 and F2840 and the powertrain has undergone independent bench testing. The total worldwide Pipistrel Electric aircraft fleet has more than 4000 flight hours (excluding NASA hours, which are believed to be significant). Several Pipistrel electric glider aircraft have already been registered and flying in the USA (in the experimental category) since December 2012, again without incident.

I would like to use the Pipistrel ALPHA Electro to train pilots. This is the ideal role for the Pipistrel ALPHA Electro and similar aircraft.

The Pipistrel ALPHA Electro aircraft that we are petitioning for exemption is based on the successful Pipistrel ALPHA Trainer aircraft, it shares the same fuselage as all other aircraft in the Pipistrel 2-seater fleet (over 1200 produced) it is the same airframe used by the Indian Army which have purchased 196 units. The Pipistrel ALPHA Electro aircraft has been designed by an EASA approved design organization, it is built and manufactured by an EASA approved manufacturing facility and the airframe used complies with existing LSA standards including the EASA, CS LSA category.

The Pipistrel ALPHA Electro aircraft has already been accepted in the LSA category internationally where the different CAA’s accept the ASTM standards but do not have the word "reciprocating" in their definitions of an LSA aircraft that would block electric aircraft.

The electric propulsion system is more reliable than a gasoline powered equivalent. The electric motor and systems require no maintenance on the propulsion system up to the 2,000-hour TBO where the engine is rebuilt with new bearings etc. for another 2,000 hours operation. The electric motor is allowed 3 life cycles, eg 6,000 hours before needing replacement.

The battery systems are extremely reliable and have given no trouble since their introduction in 2007. The battery systems are controlled by a battery management system which is now used by other electric aircraft manufacturers around the world including Siemens in their electric aircraft.

The battery packs (which are manufactured in-house by Pipistrel) have external displays built into the battery box showing the battery health so when the battery health gets to a set figure when the battery requires replacement or refurbishment with new cells the operator is advised. As batteries deteriorate over time and use the available flight time displayed in the cockpit is also reduced. The battery system has been extensively tested with drop testing, object penetration, high and low temperatures and many other tests again with results exceeding the ASTM standards.

The battery system and the electric propulsion system are considered more reliable than a gasoline equivalent. There will be no effect on safety by allowing use of electric propulsion systems on LSA aircraft designed for flight training. Our fleet of electric aircraft are additionally equipped with ballistic parachute systems which provide whole aircraft rescue.

Please publish in the Federal Register:

The Pipistrel ALPHA Electro is exempted from Section 14 CFR 1.1 Light Sport Aircraft definition, in particular, the definition of the aircraft propulsion system in Section (6) defined as "A single, reciprocating engine, if powered." This will allow Pipistrel ALPHA Electro's to be granted an airworthiness certification as a Light Sport Aircraft.

A brief description of the nature of the exemption I am seeking:

I am requesting that the Pipistrel ALPHA Electro be exempted from Section 14 CFR 1.1 Light Sport Aircraft definition, in particular, the definition of the aircraft propulsion system in Section (6) defined as "A single, reciprocating engine, if powered." This will allow Pipistrel ALPHA Electro's to be granted an airworthiness certification as a Light Sport Aircraft